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20 Questions Employers Should Ask Before Starting a Workplace Wellness Program

In January 2021, The CPA Journal published a now-classic checklist of questions for employers considering workplace wellness programs. Five years later, the questions still matter — but the answers have evolved with the payroll-tax-funded model. Here's the updated framework.

The original CPA Journal article — "20 Questions About Establishing a Health and Wellness Program in the Workplace" — laid out a thoughtful, accountant-minded checklist for any employer thinking about adding a wellness benefit. We recommend reading the source. Below is our own 20-question framework, organized into the four categories most employers actually wrestle with: design, compliance, funding, and engagement.

Five questions about program design

1. What problem are we actually trying to solve? Reduce healthcare claims? Improve retention? Differentiate in recruiting? Each of those points to a different program shape. A program that's "everything for everyone" usually delivers nothing for anyone.

2. What does our claims data tell us about where to focus? If your top cost driver is mental health and ER utilization, a chronic-disease screening program won't move the needle. Match the program to the actual data.

3. Does the program address all dimensions of wellbeing? The strongest evidence base supports programs that touch physical, mental, and emotional health together — not single-axis interventions like a gym discount alone. EmployWell's three-pillar structure exists for this reason.

4. Is the program substantive or symbolic? A wellness benefit that's mostly marketing language doesn't survive an IRS audit and won't move utilization. Real programs include measurable services — coaching, telehealth, screenings, mental health access — not just newsletters.

5. Will the program scale across our locations and shifts? Hourly workers, second-shift workers, and remote employees all need to be able to engage. If the program requires showing up in person to HQ between 9 and 5, you'll get HQ-only participation.

Five questions about compliance and legal structure

6. Is the program structured under Section 125? If you want FICA savings, the answer must be yes. Here's a primer.

7. Are the plan documents written, adopted, and distributed? A Section 125 plan requires a formal written plan document and a summary plan description in employees' hands before benefits begin. Backdating doesn't work.

8. Has the plan been tested for nondiscrimination? Section 125 plans must not disproportionately favor highly-compensated employees. Annual testing is required.

9. Is the program HIPAA-compliant in how it handles employee health data? Wellness programs that collect biometric data, screening results, or health surveys must comply with HIPAA's privacy and security rules. Ask the vendor for their Business Associate Agreement.

10. Does the program comply with ADA, GINA, and applicable state laws? Voluntary participation, reasonable accommodation, and confidentiality of family medical history all matter. A reputable vendor handles all three.

Five questions about funding and ROI

11. What's the gross cost of the program, and what's the net cost after FICA savings? A correctly structured program has a net cost of zero — or even a positive cash flow — once Section 125 FICA savings are factored in. If a vendor can't show you that math clearly, ask why.

12. What's the projected take-home pay impact for employees? Employees see a real boost — typically around $820/year per participant — because their FICA-eligible wages drop. That's a tangible benefit you can communicate at open enrollment.

13. How do we measure ROI beyond Year 1? Year 1 ROI is mostly tax savings. Years 2–5 are where utilization data starts moving. Ask the vendor what reporting they'll provide on engagement, claims trend, and aggregate health outcomes.

14. What happens if we're audited? A real vendor stands behind the plan documents and provides audit support. Get this in writing.

15. What's the implementation cost in time, not just money? Most employers underestimate the internal time required for a benefits launch. EmployWell's typical implementation is 45 days, with payroll integration and employee enrollment handled by the vendor — not by your internal HR team.

Five questions about employee engagement

16. How will we communicate the program to employees? Engagement starts with employees understanding what they get. The strongest programs include a launch toolkit, manager talking points, and ongoing reminders — not just an email blast at enrollment.

17. What's the expected participation rate, and how is it measured? A well-designed program with proper communication achieves 75–90% participation. If a vendor projects materially less, dig into why.

18. Can employees access the program from a phone, on their schedule? Mobile-first access is non-negotiable for hourly and shift-based workforces. The Anura app, on-demand video libraries, and 24/7 telehealth in EmployWell exist for this reason.

19. Is there a culturally and linguistically diverse offering? If 30% of your workforce speaks Spanish at home, a program available only in English will reach only 70% of your team — at best.

20. What's the off-ramp if we ever want to leave? Reputable vendors don't lock you in. Ask about the exit process: what happens to plan documents, how employees are transitioned, and what notice is required.

The questions employers most often miss

Of those 20, the three we see employers skip most often are:

If you're early in the evaluation process, those three are worth a hard look before any vendor demo.

Have your 20 questions answered.

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